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Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485
I object to this project because despite costing billions of dollars, the M4/M5 tunnel will not significantly solve the problem of traffic congestion in Sydney. In fact, it is likely to make it worse.
I agree with the City of Sydney that this EIS is based on the fallacy that the M4 and-M5 need linking when they are already linked by the M7, A6 and A3.
The proposed link between the two motorways duplicates the A3, a national road which probably needs an upgrade but does not appear to need duplication many kilometers further east. The eastern link between the M4 and M5 doesn’t offer any obvious benefits to drivers in or from western Sydney.
According to AECOM’s EIS report for the benefits of this project to be fully realised, the F6, Western Harbour Tunnel, Beaches Link and the Sydney Gateway would need to be completed. In other words, this project depends on other tollways being built which are little more than concepts with no business case or planning approval.
These projects were not included in the WestConnex business case. They are not priority projects in any state or Federal roads plan. Indeed according to the EIS, even if all of these tollways were built, the whole Sydney network would only be 10% more productive than it is now. This makes no sense and is an outrageous drain on human, natural and financial resources.
The original purpose of the WestConnex project was to improve and extend the M4 motorway and to connect the M5 to Port Botany and to Sydney Airport. Improving the road system for trucking freight was supposed to be the principal purpose. None of the three stages goes to Port Botany or to the airport.
Neither the new M5 (needed for the large trucks which cannot use the existing M5) nor the stage 3 tunnels go to Port Botany. For that there is a separate project proposal, the Sydney Gateway, for an additional tollway to move freight from the port to distribution centres further inland or directly to final destination (see Section 4.1.4 EIS Project development and alternatives). So it is misleading to claim improvement in freight movement as a benefit of this project. Instead the link to the M5 interchange at St Peters and the new M5 – if they fulfill expectations of numbers of vehicles using them – will deliver 1000s of vehicles onto the roads to the airport which are already at capacity.
This stage 3 project will build another tollway but the revenue will not go to cover the cost of construction of the new roads and tunnels but to provide revenue to private investors for 40 years. This stage will deliver none of the promised connections to the Sydney Airport or Port Botany which were the purpose of the original WestConnex project. While we are told repeatedly that WestConnex will benefit the people of Western Sydney, the reality is that drivers from western Sydney will generate ever increasing revenue to investors in the operators of roads that do not serve their needs.
Traffic modelling is an inexact process
Traffic modellers acknowledge that traffic modelling is a very inexact science. There is insufficient acknowledgement of this in the EIS.
Given the highly uncertain nature of traffic modelling, it is likely that even this claimed benefit would not eventuate. In any case any so-called ‘benefits’ needs to be considered in the light of all the other costs including the severe construction impacts over more than 8 years, lost opportunities including investment in other transport solutions, the future health, environmental and economic costs of encouraging car dependency and economic pressures created by toll roads.
The concept of congestion which even this EIS acknowledges will be a legacy of WestConnex are considered too narrowly in this EIS. as ‘traffic congestion’ rather than delays to reliable and efficient access to human capital, goods and services which reduces economic activity and productivity. This results in an incorrect and misleading assessment.
However even within the narrow AECOM definition of ‘traffic congestion’, the EIS acknowledges that traffic congestion will be a legacy of WestConnex and reports that NSW Roads and Maritime Services is already working on more road building works in the future that will solve some of problems created by this tollroad building spree.
It is disturbing to see that the same method and logic used to develop and assess all the stages of WestConnex is similar to methods that have delivered numerous motorways around Australia that have not only failed to ease congestion, but have made it significantly worse.
There is no reliable evidence presented (or available) that building motorways reduces traffic congestion over the long term. No major urban arterial road project, without carefully considered and implemented pricing signals, has succeeded in easing congestion for more than a few years. This is universally acknowledged in planning disciplines. Why is there no evidence of the use of independent academic research in the preparation of this report by AECOM?
Unwarranted assumptions underpin traffic analysis
Unwarranted assumptions are made in the traffic analysis. In the case of the Western Harbour Tunnel, the NSW Labor party has said if elected, it would not build it. Forecasting with such uncertainty over a long time must at least mean that the claimed benefits may not eventuate and at the very least should be subject to careful independent review and testing by experts who have full access to all the assumptions on which they are based.
If this project goes ahead, there will be massive motorway interchanges with pollution stacks in St Peters, Haberfield/Ashfield and Rozelle. The EIS acknowledges that there will be traffic congestion problems around these interchanges in both 2023 and 2033. This will be a huge cost in economic and health terms. This traffic congestion will impose further costs and damaging impacts on communities that have endured up to eight years of construction. Surely in any rational and independent planning process, this finding alone would be enough to encourage an assessment authority such as NSW Planning to seriously ask whether an agenda that pushes building more and more tollways is not more of a problem than a solution. Instead all that we find is a lame proposal that NSW Roads and Maritime Services are already working on solving future congestion problems that this project would have contributed to by 2033.
Use of WRTM is deeply flawed
Reductions of volumes of traffic on Parramatta Rd, King Georges Road or the existing M5 are asserted but the model which projects these effects is not provided for scrutiny or independent assessment. The model’s margin for error is not stated. The rest of the benefits all depend on the asserted traffic reductions generating improved travel times and better bus services or freight movement etc. So far the experience of the growth of traffic on Parramatta Rd in response to the re-imposition of tolls on the widened section of the M4 gives us leave to doubt these touted benefits.
There is reference in the EIS to the WestConnex Road Traffic Model version 2.3 (WRTM v2.3), a strategic traffic model that has been used in the traffic analysis. This model was developed by the NSW Roads and Maritime Services who have constantly pushed a motorway agenda to the disadvantage of the development of more public transport. There is insufficient explanation of the nature of the model, where it can be accessed and what function it plays in the analysis. There is no clear explanation of how the assumptions that underpin the WRTM have changed between EIS stages. Since so much else in the EIS including noise and air quality predictions are dependent on this forecasting, the lack of transparency makes it difficult for the EIS to be subject to independent critique.
Tokenistic analysis of public transport alternatives
The EIS pays lip service to WestConnex being part of a “broader solution” but in fact the analysis of public transport alternatives is tokenistic . Academic and independent research which provides alternative approaches to transport planning is ignored. I am particularly disturbed that there is no serious engagement with the City of Sydney alternative to the WestConnex solution.
The discussion of alternatives to building the M4-M5 link is limited and not given the detailed scrutiny which enables the public to assess them on the same basis as the tunnel project. For example upgrading the A3 as an alternative to the link is not discussed, modelled or costed although the section admits that the intersection of King Georges Road rebuilt as part of the new M5 project is expected to improve capacity.
Upgrading and extending the passenger train service alternative for Western Sydney – which is the preferred alternative of commuters travelling to the CBD from Western Sydney – is dismissed with:
“A scoping study to better understand the need, timing and service options for rail investment to support western Sydney and the Western Sydney Airport” [is underway] p.4.18.
The improvement of the public heavy rail train services by upgrading of tracks and the signalling system is not canvassed at all. Only the (private) Sydney metro and light rail extensions are identified with high capital costs or none cited. Since these are all private developments it is not clear why their capital costs are relevant. The impact of these new services on passenger/commuter needs is not included in assessing the need for the WestConnex project in this discussion. The bus service discussion is focused on moving commuters west to east as mass transit and dismisses local and suburban services in three sentences which are centred on Parramatta Rd. Bus service needs further west are not mentioned. The discussion of active transport alternatives gets no further west than Parramatta.
The summary discussion of public transport “constraints” is very general, focused the need to relieve congestion on arterial roads, not the cross suburban needs of people living and working in Western Sydney. The benefit of the WestConnex stage 3 project is dependent on reducing the surface road traffic on Parramatta Rd and Victoria Rd but it is not at all clear that this project will have that impact and in any case depends on other separate projects, principally the Sydney Gateway.
Rather than ease congestion the project is likely to reduce the availability of funds for projects that genuinely reduce congestion (road pricing) or give priority for high productivity road users such as delivery and service vehicles.
Since this EIS was lodged, there have been media reports that the NSW public transport budget has been cut. Public transport projects would genuinely contribute to avoiding traffic congestion. There should be a transparent investigation into whether the WestConnex project is actively contributing to the government turning away from alternatives to WestConnex and further tollways.
Demand management is dismissed as either taking too long to have an effect, is dependent on psychology or the demographics are against it. This is not a serious discussion of using pricing or other measures to encourage people to time their road use differently or change transport modes. On the other hand the experience already of the impact of the new tolls on the widened M4 demonstrates the real effect of pricing signals.
Anzac Bridge and CBD will be even more congested
Those who read the full EIS ( which is extremely difficult for most people to do) will find that Anzac Bridge (projected 60% increase in daily traffic) and Sydney City Centre (CBD) will be inundated with more traffic. Bus transport along these routes will be slower and less reliable. It is outrageous that a 21st century infrastructure project would actually worsen public transport options.
The section on tolls in this document is remarkably brief given their impact on the drivers of Sydney who will be affected by them for 43 years.The discussion admits that the tolls are inequitable. People on lower average incomes driving to work will find the burden of daily tolls are a significant impost.
Benefits depend on unplanned, unapproved tollroads
Arguments in support of the project depend on the approval of further toll roads. These other proposals, such as the F6, are being planned secretly. There are reports that the F6 will take hundreds of houses and parks. I am opposed to Stage 3 being be approved on the basis that such a project would be completed.
Slowing down public transport
Just as with the other stages of WestConnex, this project would slow down public transport on some corridors. Buses travelling to the CBD will be slower, despite the construction of a tunnel between Iron Cove and the Anzac Bridge.
Inadequate traffic modelling
The traffic modelling has not been adequate to model the impact on local roads. The explanation given by AECOM at public EIS sessions to this criticism is that the parameters of the traffic modelling are dictated by NSW RMS. While this may be true, it provides no excuse for why the resultant EIS is inadequate.
In assessing the project it is crucial to understand impacts of dispersed traffic on connecting roads, such as the Anzac Bridge, and whether they have available capacity to meet the predicted traffic discharge. Any congestion on exits has the capacity to negate all travel time savings to the exit point, given the small predicted benefits. What is the point of speeding through a tunnel if you end up sitting in a traffic jam?
Johnston Street, The Crescent/Minogue Crescent and Ross Street
The modelling area shown in Figure 8-5 should be extended to include Johnston Street and The Crescent/Minogue Crescent/Ross Street corridor to Parramatta Road to provide clarity on how these feeder routes are envisaged to operate in 2023 and 2033. It should include the modelling assumptions applied.
There is also insufficient traffic modelling to reveal the impact on Erskineville Road and Edgeware Rd, both of which are already highly congested and will be negatively impacted by traffic emerging from or avoiding the New M5.
Traffic exceeding operating limits
If one assumes that the modelling is correct, it shows the Stage 3 motorway would exceed reasonable operating limits in the peak in less than ten years. On the other hand, there are already reports that the levels predicted will not be profitable enough and will in fact be less than predicted. ( (SMH ‘Pressure builds on government to sweeten WestConnex sale’ 5/10/2017). This contradiction merely highlights how unpredictable the traffic analysis is and why there should be a transparent review assisted by independent experts and a public report before any more approvals are given.
Infrastructure Australia compared predicted and actual traffic levels and found that the assumed steady growth in traffic did not occur. In Sydney, urban congestion levels are growing at around one third of the forecast rate. (See Figure 1, below)
More specific problems
Where the modelling shows traffic beyond capacity at The St Peters / Sydney Park Interchange resulting in an overloading of the Mascot road network, traffic levels were reduced to fit the modelling.
The modelling has thousands of unreleased cars at key locations; i.e. in reality those unreleased vehicles would result in vehicle queues and or network failure.
The modelling shows severe traffic levels and increased congestion on Johnston St, and The Crescent (+80% ADT). The modelling shows significant increases in traffic on Victoria Rd (+20% ADT) which is already at capacity.
Key intersection performance tables in App H (p.258 St Peters and 248 Rozelle) demonstrate that many intersections will either worsen (at the worst case scenario of LOS F) or remain unchanged particularly in 2033, including the following intersections:
- Princes Highway/Canal Road
- Princes Highway/Railway Road
- Unwins Bridge Road/Campbell Street
- Campbell Road/Bourke Road
- Princes Highway/Campbell Street
- Ricketty Street/Kent Road
- Gardeners Road/Kent Road
- Gardeners Road/Bourke Road
- Gardeners Rd/O’Riordan Street
- Victoria Road/Lyons Road
- Victoria Road/Darling Street
- Victoria Road/Robert Street
The People’s EIS regards these results as unacceptable. There must be a form of public policy that does not deliberately set out to downgrade the environment of thousands of people. This will also worsen conditions for freight and business.
The proponent excludes the impact of the Western Sydney Airport from analysis of the project. This could have a significant impact on traffic volumes.
The project would have significant impacts on the streets near on- and off-ramps. Modelling shows that the Anzac Bridge will have 60% more traffic in 2033 because of the project. This is absurd and it is difficult to see how any serious transport planner could see this as a solution. It is simply a recipe for more road building contracts in the future.
As noted above, the EIS finds that the project would cause additional traffic congestion on a number of key roads including: Gardeners Road and Bourke Road in the south, Frederick Street (Ashfield), Johnston Street (Annandale) and numerous streets in Mascot (p.8-103). While the need for future upgrade work is acknowledged, the costs of this traffic congestion and the costs of more road building have not been factored into the conclusions of the Social and Economic Impact report.
Insufficient consideration of toll avoidance
Reports prepared for investors have already acknowledged that toll avoidance may be greater than acknowledged in the EIS. Already the traffic on the M4 widening shows that it may not meet earlier EIS predictions. Cost of living pressures have increased and people may be more likely to avoid the tolls than predicted by previous research. The NSW government may have underestimated that anger at the inequity of motorists using the widened M4 being expected to pay for roads mostly used by others.
The Secretary’s Environmental Assessment Requirements (SEARs) for the EIS (Page 8-2 – Table 8-1) require the Applicant to consider the operational transport impact of toll avoidance however information provided on toll avoidance in Chapter 9.8 (Page 222) of Appendix H is limited to four short paragraphs. This does not meet the requirement. It simply shows that AECOM, the authors of the issue, did not consider it part of their job to assess the issue of toll avoidance. The economic and social impact of toll avoidance should also have been more thoroughly considered in the Social and Impact report.
- It is highly likely that the EIS traffic report will turn out to be inaccurate.
- It fails to properly or adequately assess the impact on local roads.
- It fails to adequately consider tolls avoidance.
- To the extent that it does accurately predict impacts and traffic changes, it shows that WestConnex will produce not solve traffic congestion.
- Indeed in many respects, it shows that traffic will be worse as a result of Stage 3. Any positive case depends on the building of other tolls roads which have not been planned or approved and to which there are many objections.